Exemption of Certain Representatives from COB Training Requirements

In terms of section 29 of the Determination of Fit and Proper Requirements for Financial Services Providers, 2017 (“Determination”), representatives must, prior to rendering any financial services, complete class of business training (CoB) relevant to the financial products for which they are appointed. This requirement came into effect on 1 August 2018.

Although the transitional provisions of the Determination makes provision for representatives who were appointed prior to 1 August 2018, representatives appointed on or after 1 August 2018 are currently subject to the CoB requirements.

In terms of the exemption set out in Annexure A to the Consultation Paper: Exemption of Services under Supervision, published on the web site of the Financial Sector Conduct Authority (“the Authority”) on 31 July 2018 (“Draft Services under Supervision Exemption”), representatives will be allowed to render financial services under supervision whilst completing the relevant class of business training requirements.

On 6 August 2018, the FSCA published the Exemption of Certain Representatives from Class of Business Training Requirements, 2018 (“the Exemption”).

In terms of the Exemption, a representative who has a date of first appointment of 1 August 2018 or thereafter, or a specific representative (as defined therein) who is appointed for a Tier 1 product for the first time on or after 1 August 2018, has until 31 January 2019 to comply with class of business training requirements.

The purpose of the Exemption is accordingly to allow representatives appointed on or after 1 August 2018 to continue to render financial services under supervision whilst completing the relevant class of business training, pending the finalisation and publication of the Draft Services under Supervision Exemption.